ML20204F157
| ML20204F157 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/19/1983 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Bauer E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 8304290013 | |
| Download: ML20204F157 (31) | |
Text
.
L 4
APR 19 1983 DISTRIBUTION:
jDocument Contro[(50k352)!
NRC'PDR~
L PDR NSIC Docket Nos. 50-352/353 PRC LB#2 Rdg.
EHyl ton REMartin Mr. Edward G. Bauer, Jr.
AHodgdon, OELD Vice President & General Counsel ACRS (16)
Philadelphia Electric Company ELJordan, DEQA:IE 2301 Market Street JMTaylor, DRP:IE Philadelphia, Pennsylvania 19101 Region I, RA
Dear Mr. Bauer:
Subject:
Limerick - Draft Fire Protection Section of the Safety Evaluation Report Enclosed is a draft of the fire protection section of the staff's safety evaluation report for the Limerick Cenerating Station (LGS). The staff has reviewed the LGS Fire Protection Program through Amendment No. 45 to the operating license applicaticn which includes Revision No. 2 to the Fire Protection Program submitted by letter dated January 28, 1983.
As noted on pages 27 and 28 of the enclosed draft, the staff has identified 34 open items requiring resolution.
The Project Manager, Mr. R. E. Martin, will contact you in the near future to arrange for a meeting (s) at which we will expect you to be prepared to commit to a course of action to allow these open areas to be satisfactorily I
resolved on a schedule which will not impact your construction completion date.
1 Sincerely, Original signed by A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing
Enclosure:
As stated cc w/ enclosure:
See next page 8304290013 830419 PDR ADOCK 05000352 F
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OFFiClAL RECORD COPY usam --m-m
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e n-Mr. Ecward G. Bauer, Jr.
Vice Presicent & General Counsel i
Philace' hia Electri: Conpany l
2301 Market Street
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l Philadelphia, Pennsyliania 19101
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Troy L..C6nnir,' Jr., Esquire Mr. Marvin I, Lewis
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Conser and'Witterhahn
"? 6504 Bridford" Terrace W "'P l
1747 Pennsylvanih Avenue, S. W.
Philadelphia, Pennsylvi6ia 19149 Washington, D'. C. 20006,.
l Frank R. Romano,'Chairini6 l
Mr. Thomas Y. Au Aii &' Water' Po11utioh'PitFo1 F Assistant C' unssi 10'* -
61 Forest Avenue l
o Comanwealth of Pehhsy1Yania, DER Ambler, Pennsylvania '19002".
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505' Executive House
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P. 0.' Box 2357 Charles W. Elliott,' Esquire.
Harrisburg, Pennsylvania'17120 Thomas & Hair.~.
". 9 50 -
123 North'Fifth Street.' h ?
Honorable'tawrence Coughlin Allentown, Pennsylvania 18102 House of Representatives E ' ' ' ~7Ih Congress ~ of the' United' States Judith A. Do'sej, Esquiri',
r Washington, D. C. 20515 l
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Limerick Ecology Action 1315'Whinut Street, Suits 1632 Roger B. Reynolds, Jr., Esquire Philadelphia, Pennsylvania 19107 l
324 Swede Street Norristown, Pennsylvinia 19401 Mr. Karl Abraham Public Affairs ~ Officer 5 County Solicitor- '
Region I C
Frederic M.' Wentz -
U.S. Nuclear Regulator 9 Commission County of Montgomery 631 Park Avenue Courthouse King of Prussia, PA,,19806 t'orristown, Pennsylvania 19404 Mr. Suresh Chaudhary ' -
Eugene J. Bradley Resident Inspector Philadel phia Electric Company U.S. Nuclear Regulatory' Commission Associate General Counsel P. O. Box' 47 L' ? -
2301 Market Street Sanatoga, PA 19464 Philadelphia, Pennsylvania 19101 Joseph H. White III
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Mr. Vincent Boyer 8 North Warnc< Avenue" l
Senior Vice President Bryn Mawr,'PA 19010'
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Nuclear Operations Philadelphia Electric Company James M. Neill, Esquire 2301 Market Street Associate Counsel for Del-Aware Philadelphia, Pennsylvania 19101 Box 511 Dublin, PA 18917
4 2
inomas Gerusky, Director Sugarman & Denworth Bureau of Radiation Protection Suite 510 De:t. of Environmental Resources North American Building 5th Floor, Fulton Sank Bldg.
121 South Broad Street Third & Locust Streets Philadelphia, Pennsylvania 19107 Harrisburg, Pennsylvania 17120 Donald S, Bronstein,,Esq. -,-
Director,; Pennsylvania. Emergency The National-Lawy.ers Guild
, Third Floor:
Management Agency -
Basement, Transportation &
1425 Walnut Street -
Safety. Building Philadelphia, Pennsylvania 19102 Harrisburg;-Pennsylvani& 17120
, u n,:
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-: p Lawrence Brenner; Esq.q :
Robert L. Anthony
, er-
,: Administrative Judge
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Fr_iends of the Earth of the Atomic Safety & Licensing Board Delaware U.S. Nuclear Regulatory Commission 103 Vernon, Valley Lane... Box 186-Washington,- DC 20555.- - '
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Moylan,;P;ennsylvania :19065,_
Dr. Peter; A. Morris r-Administrative Judge-W. Wilson Goode Managing Director Atomic Safety & Licensing Board s
City of Philadelphia U.S. Nuclear Regulatory Corxnission Philadelphia, Pennsylvania 19107 Washington, DC 20555 Walter W. Cohen Dr. Richaid F. Colel Consumer Advocate Administrative Judge-Of fice of Attorney General Atomic Safety & Licensing Board 325 Strawberry Square U.S. Nuclear Regulatory Commission riarrisburg, Pennsylvania,17120 Washingtcn, D. C.
20555 Steven P. Hershey, Esquire Consumers' Education & Protective Association Sylvania House Juniper & Locust Streets
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Philadelphia, Pennsylvania,19107 Alan J. Nogee The Keystone Alliance 3700 Chestnut Street Philadelphia, Pennsylvania 19104
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Draft Safety Evriluation Report Limerick Generating Station Unit Nos. 1 & 2 Docket Nos. 50-352/353 l
9.5.1 Fire Protection We have reviewed the fire protection program for conformance with SRp 9.5.1 (NUREG-0800), which contains, in BTP CMEB 9.5.1, the technical requirements of Appendix A to BTP ASB 9.5-1 and Appendix R to 10 CFR 50.
Because the applicant has compared his program to the latter guidelines, this report also references these guidelines.
In response to our request for an evaluation of the Limerick fire protec-tion program against the guidelines of Appendix A to BTP ASB 9.5-1, the applicant, by Amendment 45, transmitted his fire protection evaluation report.
At the same time, the applicant also provided an evaluation against the requirements of Appendix R.to.10 CFR 50.and.BTP. CMEB 9.5.1.
(NUREG-0800, July 1981).
As part of our review, we will visit the plant site to examine the relationship of safety-related components, systems, and structures in specific plant areas to both combustible materials and to associated fire detection and suppression systems.
The site visit has not yet been conducted because the construction has not progressed to a level where such a visit would be meaningful.
Our review included an evaluation of the automatic and manually operated water and gas suppression systems, the fire detection systems, fire barriers, fire doors and dampers, fire protection administrative controls, and the fire brigade size.
The objective of the review is to ensure that in the event of a fire, personnel and plant equipment would be adequate to safely shut down the reactor, to maintain the plant in a safe shutdown condition, and to minimize the release of radioactive material to the environment.
DRAFT
i
. Because Units 1 and 2 are of the same design (except as noted), the comments made in this report apply to both units.
j Our consultant, Gage-Babcock and Associates, Inc., participated in the review of the fire protection program.
W5 In cur review of the applicant's comparison of,M1T fire protection program to BTP CMEB 9.5-1 (NUREG-0800), we have utilized the applicant's submittal dated January 28, 1983.
For several of the categories, the applicant has provided amplifying information. We have evaluated this additional information to verify that the applicant is meeting our guidelines.
However in the following areas, the applicant has not provided the necessary information for us to independently verify compliance with our guidelines:
j 1.
BTP CMEB 9.5-1 Section C.1.a - Fire Protection Program 2.
BTP CMEB 9c5-l'Section C.2 -Administrative-Controls' -
3.
BTP CMEB 9.5-1 Section C.3 - Ffre Brigade 4.
BTP CMEB 9.5-1 Section C.4 - Quality Assurance 5.
BTP CMEB 9.5-1 Section C.S.a(6) - Stairwell Protection 6.
BTP CMEB 9.5-1 Section C.S.a(8) - Cable Spreading Room Protection j
7.
BTP CMEB 9.5-1 Section C.7.b - Control Room Complex Separation 8.
BTP CMEB 9.5-1 Section C.7.i - Diesel Generator Separation 1
We [ 1 require that the fire protection program be operational before initial fuel loading.
q,6, l, [.1 Fire Protection Program Requirements
- 1,s l./,/ [ Fire Protection Program J
The applicant has committed to conform with the guidelines in BTP CMEB 9.5-1, Section C.1.a without providing sufficient information for us to independently verify compliance with
'hidelines.
We g
DRAFT
- prequire that the applicant provide descriptions of how the fire protection organization, responsibility assignments, and personnel qualification comply with the guidelines in BTP CMEB 9.5-l Item y
C.1.a.
'i.S.I,l 2f.
Fire Hazards Analysis The applicant's fire hazard analysis specified the combustible materials present in fire areas, identified safety-related equipment, determined the consequences of a fire on safe shutdown capability, and summarized available fire protection in accordance with BTP CMEB 9.5-1, Section C.1.b.
Our evaluation of the identified fire hazards is in the paragraphs below.
Alternative shutdown capability has been provided for the control room and cable-spreading room.
The capability also is evaluated below.
GDC 3, Appendix A-to -10 CFR Part 50 requiYes that ~" Fire fighting" '~
systems shall be designed to assure that rupture or inadvertent operation does not significantly impair the safety cepability of those structures, systems and components."
To satisfy this requirement the applicant has designed components required for hot shutdown so that rupture or inadvertent operation of fire suppression systems will not adversely affect the operability of these components.
Where necessary, apropriate protection is provided to prevent impingement of water spray on components required for hot shutdown.
Redundant trains of components that are susceptible to damage from water spray are physically separated so that manual fire suppression activities will not adversely affect the operability omponentsnoginvolvedinthepostulatedfire.
However, we cann of E E O $d th t th mechanismgby which fire and fire fighting systems may cause the simultaneous failure of redundant or diverse trains have been considered in the design.
WeypWI require that i
l OS the applicant identify such mechanisms that were considered in W l
fire hazards analysis and the measures taken to preclude the fire or i
fire suppressant induced failure of redundant or diverse safety trains.
I j f,l, 2,_ -Od" Administrative Controls The administrative controls for fire protection consists of the fire protection program and organization, the fire brigade training, the controls over combustibles and ignition sources, the prefire plans j
and procedures for fighting fires, and quality assurance.
The appli-cant has committed to meet our guidelines in Section C.2 of BTP CMEB 9.5-1 however has not provided sufficient information for us to 1
independently verify compliance with 7(resE.e w guidelines.
We [ require tnat the applicant provide details showing compliance with the guide-4 lines in BTF CMEB 9.5-1, Item C.2 regarding administrative controls.
T
$ (,l, $ dht-Fire Brigade and Fire Brigade Training i
The applicant, has not provided a description of the plant fire brigade, including equipment and training to verify the guidelines contained in BTP CMEB 9.5-1 Item C.3.
We g require that the applicant provide details showing compliance with the guidelines in BTP CMEB 9.5-1, Item C.3 in the establishment and training of the fire brigade.
Fire t/6L Brigade training evaluated in Section 13.2.2 of this report.
- 9.f, /, 4 --En4-General Plant Guidelines 9,8, /,4, l % Building Desian Fire areas are defined by walls and floor / ceiling assemblies.
Walls that separate buildings and walls between rooms containing safe shut-down systems are 3-hour-fire-rated assemblies.
In cases where the fire rating is less than 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, we have evaluated each individual DRAFT
a 4
, area with respect to its fuel load, fire suppression and detection systems, and proximity to safe shutdown equipment to determine if the fire-rated assemblies provided are adequate for the areas affected and meet the guidelines in Section C.S.a of BTP CMEB 9.5-1.
Based on this evaluation, we find that the protection provided in the following areas does not meet eter hukelines:
1.
In many areas the structural steel supports of floor assemblies are not provided with a fire protective covering, resulting in unrated floor assemblies.
We *4++ require the exposed steel structural supports to be protected to provide 3 br. fire resistance in all areas containing safe shutdown systems and in all other areas where the structural failure of the unprotected steel would affect areas containing safe shutdown systems in accordance with Section C.S.a of BTP CMEB 9.5-1.
2.
The doors-between1hetrbinetuilding and areas of-the plant"--
containing safe shutdown systems are not labeled fire doors.
Although these steamtight doors are certified by the manufacturer to be constructed in the same manner as the labeled doors, their, method of installation as a steamtight door generally precludes the necessary gaps for expansion and distortion for a labeled fire door assembly and woul"d probably not provide the necessary fire resistance.
We g require that either labeled 3 hr. fire door assemblies be provided at all such openings or replicate assemblies of the steamtight doors be tested by a nationally recognized testing laboratory to show that they provide equivalent J
fire protection when subjected to the ASTM E-119 time temperature i
curve for 3' hours.
l BRAFI
. The applicant will provide penetration seals for all penetrations of fire rated walls or floor / ceiling assemblies.
The penetration seals have been subjected to qualification tests using the time-temperature curve specified by ASTM Standard E-119, " Fire Test of Building Construc-tion and Materials".
The test acceptance criteria used by the applicant would permit temperatures up to 325"F above ambient on the unexposed side of the seal.
Our guidelines recommend that a maximum temperature of 325*F be used as the acceptable level.
The applicant's higher acceptance criteria of 325*F above ambien _t could permit the acceptance of penetration seals that would cause fire damage to unexposed cables in a shorter time period than would penetration seals meeting our guidelines.
We y MT require the applicant to verify that none of the penetration seals used will permit a temperaturej M n excess of 325*F on the unexposed-side as recommended 'by BTNB"9:5-1"Section" Cr5 rat 3,"-"
or to justify the deviation from our guidelines.
The applicant has not provided a description of the 2-hour 'ated fire r
barriers for the plant enclosed stairwells for us to independently verify compliance with our guidelines.
WepMfrequire the applicant to provide details showing compliance.with Section C.5.c of BTP CMEB 9.5-1.
With the exception of the previously mentioned steamtight doors, the door openings in fire-rated barriers are provided with Underwriters Laboratory (UL)-labeled fire door assemblies that have ratings commen-surate with the fire ratings of the walls in which they are installed.
Ventilation ducts that penetrate fire barriers are provided with fire dampers.
The fire dampers will be UL labeled and installed according to the manufacturer's directions.
Three-hour-fire dampers will be
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provided in all 3-hour-fire rated barriers.
We conclude that the fire f
l dampers will be provided in accordance with the guidelines of BTP CMEB 9.5-1, Section C.5.a and are, therefore, acceptable.
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_ Thermal insulating materials are noncombustible.
They have flame-spread and smoke-develope atings of 25, and 50, respectively, as tested by UL.
Interior walls and structural components, rs, ' ion shielding materials, and sound proofing and interior finishee are noncombustible or listed by a nationally recognized testing laboratory, such as Factory Mutual or UL, for flame spread, smoke, and fuel contribution of 25 or less.
We find h is in accordance with the guidelines of BTP CMEB 9.5-1, SectionC.S.aandf,therefore, acceptable.
4 Metal roof deck construction is a UL listed Class A assembly.
The Class A rating indicates that the roof assembly is effective against severe external fire exposures.
This does not meet our guidelines in Section C.S.a(10) of BTP CMEB 9.5-1, as the roof assembly has not been tested for performance under internal fire exposures.
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We % require the applicant to provide metal roof deck co.1struction that is classed " acceptable-for-fire"-in'the1t-Building" Materials- ""--
l directory or which meets the criteria for Class 1 roof deck systems in the FM system approval guide.
Transformersinstalledinsidebuildinchs are either air cooled, of the dry type or are insulated and cooled with a noncombustible liquid.
The main and plant services transformers l
are located greater than 50 feet from any buildings or are separated by 3-hour fire walls.
The safeguard and auxiliary transformers are 4
located on the north side of the turbine building, within 14 ft. of the building exterior wall.
No safety-related equipment is located within the turbine building.
The turbine building exterior walls are not rated.
The transformers are protected by an automatic water deluge system.
We find this to be an acceptable deviation from the guidelines of BTP CHEB 9.5-1, Section C.S.a, because no safety-related equipment is located in the turbine building.
DRAFI
4 We conclude that the installation of the transformers with the approved direction meets the guidelines of BTP CMEB 9.5-1, Sections C.S.a(12) and 13 and is, therefore, acceptable.
Some areas of the plant are not equipped with floor drains.
The appli-j cant states that collected fire fighting water could be drained through the doorways to the adjacent rooms.
This is not consistent with our guidelines in Section C.S.a(14) of BTP CMEB 9.5-1.
It is our concern that redundant trains of safety-related equipment in unaffected areas could bg,by excess fire fighting water.
We g requir applican g provide suitable floor drains or a system of drains and curbs to prevent flooding of safety related equipment.
f, $f [,. [ +:
Safe Shutdown Capability The applicant has provided a report on the safe shutdown capability following a fire in accordance with the requirements 7f-AppendirRr '
(BTP CMEB 9.5-1 Section C.5.b) as part of the FSAR submittal.
Further discussion of the safe shutdown capability including information on cable separation and safe shutdown equipment location is containe'd in Section3 5.1.f,\\
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9 The applicant's safe shutdown analysis states that systems needed for hot shutdown and cold shutdown are redundant and that one of the redundant systems needed for safe shutdown would be free of fire damage by providing separation, fire barriers and/or alternative shutdown capability.
To achieve hot shutdown, either the Reactor Core Isolation Cooling (RCIC) System or the High Pressure Coolant Injection System (HPCI) in addition to the Main Steam Isolation and Safety Relief Valves (MS/SRV), Automatic Depressurization System (ADS) valves, the Residual Heat Removal (RHR) System Loop "A" or "B", the RHR Service Water (RHRSW)
System loop "A" or "B" and the Emergency Service Water (ESW) System Loop j
"A" or "B" would be available.
Going to cold shutdown from hot shutdown i
would require the "A" loops of the RHR, RHRSW, and the ESW or the "B" DRAFT l
. loops of the RHR, RHRSW, and ESW.
The safe shutdown review considered components, cabling and support equipment for systems identified above which are needed to achieve shutdown.
The applicant has provided a cable separation review for all rooms of the plant housing safe shutdown equipment to ensure that at least one train of this equipment is avail-i able in the event of a fire in any of these rooms.
The review identi-fied the safety-related equipment, redundant safe shutdown system cabling and discussed the consequences of a fire in each of these rooms.
We have reviewed the applicant's deterministic review of the plant and conclude that it provides an acceptable means of demonstrating that separation exists between redundant safe shutdown trains.
The applicant's review divided the areas by the diesel generator electrical division.
Cables and equipment were considered disabled in the area of the fire unless the fire hazard analysis assumed otherwise.
No repairs were assumed.
The applicant has also indicated that alternative shutdown-iscrecuireddor-themntrol roonrrr-In-the "--
et_.
event that fire disables the control room a remote shutdown panel 3
located in a separate fire protected room in the control structure is provided as an alternative to providing fire protection.
The remote shutdown panel is electrically isolated from the control room. ' Refer ab to Section 9.5 c of this SER for further discussion on the alternative g
shutdown capability.
We have reviewed the means of separation proposed to ensure that one 9
train of cables and equipment needed to safely shutdown the plant will be maintained free of fire damage.
In the following areas, the appli-cant has not met our guidelines in Section C.S.b of BTP CMEB 9.5-1.
(g)
Fire Area 2, 13 kv switchgear area Deficiency:
Separation not specified 30 minute barrier in lieu of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> No automatic suppression J
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Fire Area 7, Corridor elev. 239' Deficiency:
Separation not specified 30 min. barrier in lieu of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> No automatic suppression.
3 Fire Area 12 Unit 1, 4kv Switchgear Area Deficiency:
No automatic suppression Fire Area 20, Unit 1, Static Inverter Compartment Deficiency:
No automatic suppression Fire Area 25, Aux. Equipment Room Deficiency:
Separation Not Specified No barriers provided i
No automatic suppression above floor Fire Area 27, - Control-Structure-Fan-Room---
1 Deficiency:
30 min. barrier in lieu of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> No automatic suppression Fire Area 40, Corridor elev. 177' l
Deficiency:
No automatic suppression h
Fire Area 43, Safeguard System Isolation Valve Area Deficiency:
No automatic suppression 4
Fire Area 44, Safeguard System Access Area Deficiency:
Separation Not Specified 30 min. barriers in lieu of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> No automatic suppression i
.. /0 Fire Area 45, CRD Hydraulic Equipment Area and Neutron Monitoring System Area Deficiency:
Separation Not Specified 30 min. barriers in lieu of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> No automatic suppression
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Fire Area 47, RWCU Compartments, FPCC Compartment & General Equipment Area Deficiency:
30 min. barriers in lieu of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> No automatic suppression throughout the area
- 17. )
Fire Area 48, RWCU Holding Pump Compartments RERS Fan Area and Corridors Deficiency:
No automatic suppression The applicant has not justified these d viations from BTP CMEB 9.5-1 Section C.S.b.
The applfcant-Jias-$
YHndicated:that additionairt-~.r y
information will be submitted on eis i+e.T/vh dW8a eMse 1
h,8, f, h, h -e)-- Alternative Shutdown Section 7.4.1.4 of the FSAR describes the remote shutdown panel's design and capability.
The present design objective of the ren. ate shutdown l
panel is to achieve and maintain cold shutdown in the event of an evacuation due to a fire disabling the control room.
The Reactor Core Isolation Cooling (RCIC) system, safety / relief valves and one division of the Residual Heat Removal (RHR) system, RHR Service Water (RHRSW) system, and the Emergency Service Water System (ESW) can be controlled from the remote shutdown panel to achieve cold shutdown should a fire disable the control room.
In order to assure the availability of this remote shutdown panel in the event of a control room fire, transfer switches are provided to transfer to the remote shutdown panel suffi-cient equipment to provide the capability to go to cold shutdown.
These transfer switches provide electrical isolation between the con-trol room and the remote shutdown panel.
12 -
i l
j The design of the remote shutdown panel complies with the performance l
goals outlined in the requirements of Section III.l. of Appendix R (BTP 1
i CMEB 9.5-1, Section C.5.c).
Reactivity control will be accomplished 1
i l
by a manual scram before the operator leaves the control room.
The l
RCIC system will provide reactor coolant makeup, and the RHR system 4
j and the safety relief valves will be used for reactor decay heat removal.
l f.
Reactor vessel-water level, reactor vessel pressure, suppression pool l
water level and temperature, RCIC pump turbine speed and RHR system j
flow are amount the instrumentation available at the remote shutdown
)
panel to provide direct reading of process variables.
The remote shutdown panel will also include instrumentation and control of 1
j support functions needed for the shutdown equipment.
l j:
We have evaluated the fire protection provided for the camote shutdown j
panel and conclude that it is not physically separated from the control room in accordance with our guidelines in Section C.5.c of BTP CMEB 9.5-1.
The remote 2 shutdown paneluisclocatedtinithe" Auxiliarf: Equipment" m-=F'm f
Room (Fire Area 25) along with PGCC cabinets and therefore, this area contains systems for both the normal shut.down system and.the altern-j ative shutdown capability for both units.
The applicant has
.ei-, ally vnt i
indicated that additional information will be submitted on this item.
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-tt7' Control of Combustibles i
Safety-related systems have been isolated or separated from combustible 4
materials as much as possible. The storage of flammable liquids complies with NFPA 30.
Compressed gases are stored either outdoors or in nonsafety-j related structures whenever possible.
However, compressed. gas cylinders j
associated with the primary containment instrument gas system and con-l tainment' combustible gas monitoring system are located in the reactor l
enclosure.
This does not meet our guidelines in Section C.S.d of BTP j
CMEB 9.5-1.
We g require that either the cylinders be moved to non-1 i
safetyrelatedareasoracombgtionoftheconditionsofstorage j
plus fire protection provided K demonstrated to achieve an equivalent vww,,
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. level of safety.
The hydrogen piping in safety-related areas has been desig.ied to seismic Class I requirements.
Based on our evalua-tion, we conclude that the design of hydrogen piping meets our guide-lines in Section C.5.d.5 of BTP CMEB 9.5-1 and is, therefore, acceptable.
g { { Lf, ( W Electrical Cable Construction, Cable Trays, and Cable Penetrations Cable trays are of all metal construction.
Electrical cable construction i
generally passes the IEEE-383-1974 flame test.
Only lighting and communi-cations cables do not pass this test; because these ccbles are routed exclusively in conduit and are not routed wit.h cables for safety-related systems we find this acceptable.
The cables are designed to allow i
wetting down with fire suppression water without electrical faulting.
Safety related cable trays outside the cable spreading room cre not h
providert with continuouselinertype heattdetectors7:andninraany'areasm r = w
^
automatic water suppression systems are not provided.
The applicant states that smoke detectors are provided in the vicinity of cable trays, and separation of one hour barriers are provided in lieu of automatic pkjers.
cnts @ g.5 - g ot meet our guidelines in Section Th does o
C.5.e.(2)4 ine type heat detectors will detect overheating in cable trays prior to combustion.
Automatic sprinklers permit. a means of promptly suppressing incipient fires.
To meet our guidelines, we require that the applicant provide line-type heat detectors and auto-f matic sprinklers.
l
(((
Ventilation 4
i There are no ventilation systems in the plant designed specifically to exhaust smoke or other products of combustion.
Normal plant ventilation j
systems will be utilized for this purpose.
Portable smoke ejectors will be provided to assist in removal of the products of combustion j
should the normal. ventilation systems be unavailable because of damper closures or other failures.
Because the normal ventilation system is
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capable of being ie-aligned to 100% exhaust we find this acceptable.
The power supply and controls for the ventilation systems for the control structure fan rooms are not run outside the fire area served by the system.
The applicant has not provided sufficient details for us to independently verify compliance with our guidelines in Section C.S.f of BTP CMEB 9.5-1.
We w)TI require the applicant to demonstrate that a single fire will not disable both trains of ventilation needed for safety-related areas in the control structure.
Air intake and exhaust ventilation dampers in areas protected by total flooding gas extinguish-ing systems are provided with mechanisms that will close them upon actuation of the suppression system.
Stairwells are designed to mini-mize smoke infilitration during a fire.
Charcoal filters have been provided with water spray systems in accordance with Reg. Guide 1.52.
We find this acceptable.
((g g Lighting and Communications The applicant is providing emergency lighting powered from Class IE buses which automatically transfer to the standby diesel generators upon loss of the normal power source.
Emergency ac lighting is provided throughout the plant to maintain minimum lighting levels necessary for access to and operation of all safe shutdown equipment for a period greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
The emergency ac/dc lighting is normally powered from the Class IE buses.
In the event of loss of the Class IE ac source, an automatic transfer switch immediately transfers this lighting to the 125 V dc non-Class IE station battery source.
The power source is sufficient to sustain the ac/dc lighting load for approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> if offsite power is lost indefinitely.
DRAFT
O This does not meet our guidelines in Section C.S.g of BTP CMEB 9.5-1 because upon loss of offsite power only one hour of emergency lighting capability is provided. We [ require the applicant to provide 8-hour self-contained battery powered lighting units in all areas j
needed for operation of safe shutdown equipment and in access and egress routes thereto.
The applicant has not provided a fixed communication system independent of the normal plant system.
However, portable radio communications system will be provided for use by the fire brigade and other operations personnel.
The system will utilize a distributed antenna network with base station repeaters.
The distributed antenna modules will be located throughout the plant.
Although the antenna modules are not designed to o
withstand an exposure fire, the system is designed sucn that the fail-l ure of one module will not result in failure of the entire antenna system.
We find this to be an acceptable deviation.
Based on our review, we find that the communication system with the acceptable deviations meets the guidelines of BTP CMEB 9.5-1, Section C.5.g and is, therefore, acceptable.
1 G,6,f.(-O-6 Fire Detection and Suppression 0 L Sit " Fire Detection A fire detection system is provided for all areas containing safety-I related equipment except for the service water pipe tunnel (Fire Area 75). We find this acceptable due the absence of combustible materials in the area.
We cannot verify, from the applicant's fire protection report, that detection it provided for adjacent areas which present a hazardtosafetyrelatedequipmenfe.g,,therefuelingfloorareaofthe reactorenclosureandthedecontaminationareaf DRAFI
, We w) require the applicant to verify that detection is provided for all areas that present a hazard to safety related equipment in accord-ance with our guidelines in Section C.6.a of BTP CMEB 9.5-1.
The fire and smoke detection system is in compliance with NFPA 72A.
The system does not comply with the requirements of NFPA 72D in the following areas:
1.
No device is provided for permanently recording incoming signals with the date and time of receipt.
2.
Operation and supervision of the sy: tem is not the primary function of the operators.
3.
In lieu of complete reliance on NFPA 72E, smoke and fire detector locations are established by a qualified fire protection engineer. -
This does not meet our guidelines in Section C.6.a of BTP CMEB 9.5-1.
Wew)trrequiretheapplicanttoprovideasystemwhichcomplieswith NFPA 720 for a Class A system, with detectors installed in accordance with NFPA 72E.
Power for the early warning fire and smoke detection systems is provided from a Class IE ac motor control center.
In the event of loss of offsite power, the motor center is powered from the standby diesel generators.
We find that primary and secondary power supplies for the fire detection system satisfy the provisions of Section 2220 of NFPA 720 and are, therefore, acceptable.
DRAFT
~
. The detection and actuation systems for the Halon system, the total flooding carbon dioxide system, and the deluge and preaction sprinkler systems are connected to a non-Class IE de power supply.
The charger associated with the non-Class IE batteries is powered from a Class IE ac motor control center that is powered frcai the standby diesel gener-ators in the event of loss of offsite power.
W1 We find this arrangement to satisff the provisions of Section 2220 of 4
NFPA 72D, and is, therefore, acceptable.
{[ f,[, L@ Fire Protection Water Supply System The water supply system consists of two fire pumps:
one pump is elec-trically driven and the other is diesel engine driven.
Each fire pump is separately connected to a buried 12-in. water main loop around the plant.
Each fire pump has a rated capacity of 2500 gpm at 125 psign.
The fire pumps andmentrollerssare*UL 41sted. eThe"fi-re pump ~ install.._ _.
ation has been designed and installed and will be tested in accordance with NFPA 20.
The fire pumps are located in the circulating water pump house.
The fire pumps are separated by 3-hour-fire-rated barriers.
Pressure for the fire protection water system is provided by a 2 in. connection to the servi g water system.
This does not meet our guidelines in Section C.6.b(4)[BTPCMEB9.5-1.We [ require the applicant to provide a separate jockey pump to maintain pressure.
The source af water for the fire protection system is twa cooling tower basins which have a capacity of 7,200,000 gallons each, for a total capacity of 14,400,000 gallons.
For a system pumping capacity of 5000 gpm, this allows continuous operation of both fire pumps for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />.
If one cooling tower basin or supply line is not available, the remaining water source provides both fire pumps with a 24-houc DRAFT
- supply of water. Water for the fire pumps is taken from either Unit 1 or Unit 2 cooling' tower water basins through connections to the circulating water lines.
The greatest water dem:nd for the fix d fire suppression system is 2090 gpm.
Coupled with 500 gpm for hose steams, this creates a total water demand of 2590 gpm.
NFPA Standard 20,which we reference in our guidelines, recommends that a fire pump be selected for operaticn in the range of 90 to 150 percent of its rated capacity.
Because 2590 gpm falls within this range for a 2500 gpm rated capacity pump, we find that the water supply system can deliver the required water demand with one pump iiut of service.
i Yard hydrants are provided at intervals of 250-300 ft a.long the fire protection water supply loop.
The lateral to each yard' hydrant is provided with a key operated isolation valve to facilitate hydrant maintenance ~and repairs wi:thoutehutting3dowrr*any>partvoffthr:. fire'.crreer~ ~ -
~ ~.
water supply system.
Standard hose houses are provided at intervals of 650 ft in accordance with NFPA standard 24.
Approved post-indicator sectional control valves are provided to isolate portions of the underground main for maintenace or repair without shutting off the supply to primary and backup fire suppression systems that serve areas containing or exposing safety-related systems.
f Supervision has not been provided for all valves in the fire protec-tion water supply system in accordance with NFPA 26.
To meet our guidelines, in Section C.6.c of BTP CMEB 9.5-1 the type of valve supervised and the frequency at which its position is verified should be as listed below.
DRAFT
l i
' Type of Frequency of inspection Type of valve Supervision with written record Post-indicator valves every 7 days Sectional control valves every 7 days Valves in the suction and every 7 days discharge piping of the fire pumps Valves controlling water every 30 days supply to aqueous fire suppression or manual hose station standpipe systems
- Sealing valves so that the valves cannot be operated without breaking seals.
Seals should be of a charactar to prevent injury in handling and prevent reassembly when broken.
- Electrically in ac.cordance with NFPA 26 with electrical supervisory signals annunciated in the control room.
'],8,[,3,3
-e.F Sprinkler and Standpipe Systems The wet pipe sprinkler systems, deluge systems, and pre-action systems meet the provision of NFPA 13 and NFPA 15.
The areas ecuipped with water suppression systems are listed in Sections 2.2-2.5 of the appli-cant's fire protection evaluation report.
DRAFT
. The sprinkler systems and manual hose station standpipe connections to the looped interior fire protection headers are arranged and valved such that in many cases, branch connections to the headers are provided with approved shutoff valves so that groups of sprinkler systems and/or manual hose stations can be isolated without interrupting the supply to other sprinkler systems and manual hose stations connected to the same header.
This does not meet our guidelines in Section C.6.c(1) of BTP CMEB 9.5-1 because a single break in the water supply piping could impair both the primary and backup fire suppression systems.
We require the applicant to modify the design to prevent a single break or malfunction from incapacitating multiple automatic prctection systems and standpipes hose systems.
Manual hose stations 5are not-located -throughout-the' plantain accordance ;
m ---
with NFP 14.
~We [ r,equire the applicant to provide sufficient hose stations to enable the fire brigade to reach any location that could present a fire exposure hazard to safety related equipment with at least one effective hose stream.
Three in. diameter piping is used to serve up to two hose stations in some areas.
This does not meet our guidelines in Section C.6.c.(4) of BTP CMEB 9.5-1.
We ptT1 require the applicant to either provide 4" diameter piping or verify by calculation that the fire protection system can provide the flow and pressures required in NFPA 14 for these stand-pipe locations, considering the operatiora af two hose stations simul-taneously with the largest water demand flowing from any automatic suppression systems in the vicinity of the hose stations.
Standpipe system piping supply hose stations protecting safe shutdown equipment BRAFT
O are not seismically supported or designed.
This does not meet our guidelines in Section C.6.c(4) of BTP CMEB 9.5.1.
We g require the applicant to provide seismically supported piping.
g/,j,yFoamSuppressionSystems A foam system is provided for the protection of the fuel oil transfer structure and two outdoor fuel oil storage tanks, and is designed in accordance with NFPA 11.
We find this acceptable.
f,[, /, $,
4)--
Halon Suppression Systems Two separate Halon extinguishing systems are provided,for the protec-tion of the power generation control complex (PGCC) in the auxiliary equipment room.
One system serves the Unit 1 side of the room and the second system serves the Unit 2 side of the room.
Each system discharges simultaneously ~into~ al1" floor:-sectionsMnritst respectiverrer
- ~ ~
half of the auxiliary equipment room.
The Halon extinguishing systems are designed in accordance with NFPA 12A.
Each Halon system is designed to achieve a concentration of 20%
by volume within the raised flooring that it serves, with a concen-tration of 6% by volume being reached within 10 seconds after discharge begins.
The first Halon cylinder is discharged automatically and has sufficient capacity to maintain the 20% concentration for 20 minutes.
The remaining Halon cylinder which is manually discharged, provides a 100% reserve capacity.
The applicant has not provided sufficient information to verify compliance with the fire protection specifications contained in the NED0-10466 Report, Revision 2, dated March 1978, which was previously approved by us, and is the basis for our acceptance of the PGCC system. We will require the applicant to verify that the firo protection for the PGCC meets these specifications.
DRAFT
' [ y h Carbon Dioxide Suppression Systems Total flooding CO system is provided for the cable spreading rooms, 2
CO fire protection is provided by CO hose reels in the 13.2 kV 2
2 switchgear compartment, outside both entrances to the control room, and along the north side of the turbine enclosure operating deck.
The CO systems comply with the requirements of NFPA Standard 12.
2 Based on our review, we conclude that the carbon dioxide extinguish-ing systems meet the guidelines of BTP CMEB 9.5-1 Section C.6.e and are, therefore, acceptable.
h. 6, l. $. 3-f3-Portable Extinguishers Portable fire extinguishers are provided to conform with the guidelines of NFPA 10.
We find this acceptable.
Based on our review, we conclude that these
- extinguishers-meet therguidelinesenkBIP-CMERB.S.-171SectiontW2- ----
C.6.f and are, therefore, acceptable.
M
]
9.5.1 [ Fire Protection of Specific Plant Areas g
g,
-e)-
Secondary Containment The separation of redundant cables does not meet our guidelines in Section C.7.a.1(f f BTP CMEB 9.5-1.
This was previously discussed in Section v).s.e9,5. s4, We require the applicant to provide protec-1 tion of cable trays in accordance with Section C.7.a.1(f) of BTP CMEB 9.5-1.
h,/,h, L P Control Room The applicant states that the control room complex is separated from all other areas of the plant by 3-hour-rated assemblies.
Peripheral rooms in the control room complex consist of offices.
Each room is DRAFT
t '
separated from the control room by 1-hour-fire-rated barriers.
Smoke detectors that alarm and annunciate in the control room panel are provided in each room.
However, the applicant.has not provided sufficient details of the i
control room complex for us to independently verify compliance with our guidelines. We,y4T1 require the applicant to provid.e details showing compliance with Section C.7.b of BTP CMEB 9.5-1 of our guide-lines.
Ionization smoke detectors have been installed in the control room, but not inside the individual cabinets and consoles within the control room.
This does not meet our guidelines in Section C.7.b of BTP CMEB 9.5-1.
WeJptfl require the applicant to provide cabinet detectors in accord-ance with Section C.7.b of BTP CMEB 9.5-1.
The applicant has provided an alternatenihutdownesystwfor3
'contrah:t-me 9P,6 3
room.
The alternate shutdown system is reviewed in Section of this report.
The outside air intakes for the control room ventilation system are equipped with ionization smoke detectors that alarm in the control room.
In the event of a fire, a smoke venting system can be manually initiated to purge smoke from the control room.
Automatic suppression systems are not provided for the electrical cabling routed through the space above the suspended ceiling in the control room.
WejpefIrequiretheapplicanttoprovideanareaautomaticfire suppression system above the control room ceiling to meet Section C.7.b of BTP CME 8 9.5-1.
DRAFT
~
. f, [,/,[, } g Cable Spreading Room The cable spreading room is separated from the balance of the plant by 3-hour-fire-rated walls and floor / ceiling assemblies.
All penetra-tions through fire-rated barriers are fitted with 3-hour-fire-rated dampers and/or 3-hour-fire-rated penetration seals.
However, the applicant flas not provi& d sufficient information for us to independently verify compliance with our guidelines.
We require the applicant to provide details showing compliance with the guidelines in BTP CMEB 9.5-1 Section C.7.c.
Separate cable spreading rooms have not been provided for each division of redundant safe shutdown system circuits.
However, an alternate shutdown system has been provided for the cable reading room.
The 9.
,5 alternate shutdown system is reviewed in Section of this report.
The primary fire suppression system in the cable spreading room is a total flooding carbon dioxide system.
Backup suppression capability for the cable spreading room is provided by a wet pipe sprinkler system with fusible-type sprinkler heads.
Electrical cabling is designed to allow wetting down without electrical faulting.
h, [, /,6,f [ Switchgear Rooms The Division I and Division II switchgear rooms are not separated from each other and from other plant areas by 3-hour-fire-rated walls and floor / ceiling assemblies.
Structural steel supportina the loors, is not T S.
4, 8 protected by fire rated barriers as discussed in Section of this SER. We require the applicant to protect the exposed structural steel supporting the floor assembly in accordance with Section C.S.a of BTP CMEB 9.5-1.
. Automatic fire detection is provided by ionization smoke detectors.
Manual protection is provided by standpipe hose stations and portable extinguishers.
Floor drains have not been provided in the switchgear rooms.
We require the applicant to provide floor drains or a system of drains and curbs in accordance with our guidelines in Section
)
C.7.e of BTP CMEB 9.5-1.
h,[,[,((RemoteSafety-RelatedPanels The auxiliary equipment room (Fire Area 25) is located directly above the control room and contains the PGCC panels for both units and the remote shutdown panels for both units.
A fire in this area could prevent the safe shutdown of both units.
The separation of redundant components in this area does not meet our guidelines in Section C.7.f of BTP CMEB'9.5-1.
We require the applicant to provide separation of safety related equipment in accordance with our guidelines.
9, 5, /4. l.pf Safety-Related Battery Rooms The battery rooms are not separated from each other and from the balance i
of the plant by 3-hour-fire-rated barriers, because their floor slabs are supportea by exposed structural steel.
Ionization smoke detection systems are provided in each battery room.
Hose stations and portable fire extinguishers are available in the areas for manual fire suppres-sion.
The ventilation system is designed to maintain the hydrogen levels below 2%.
Loss of ventilation alarms have been provided for each battery room.
Wew)4Trequiretheapplicanttoprotecttheexposedstructuralsteel in accordance with our guidelines in Section C.5.a of BTP CMEB 9.5-1.
J DRAFT i
I I
J
. { g j,( [ Emergency Diesel Generator Rooms The applicant states that each diesel generator and its day tank are enclosed by 3-hour-fire-rated barriers.
However, the applicant has not provided sufficient information for us to independently verify compliance with our guidelines. We w)TI require the applicant to provide details showing compliance with our guidelines in Section C.7.1 of BTP CMEB 9.5-1.
Each 800 gallon diesel fuel oil day tank is located in a separate enclosure designed with walls, floor, and ceiling that have a 3-hour-fire-resistive rating and are sized to contain the total contents of the tank.
Each diesel fuel oil day tank room.is protected by an automatic pre-action sprinkler system.
The system is activated by heat detectors.
Additional early warning-detection-is provided4by~ionizatierusmoke~~~e detectors, and flame detectors.
f, [, [,[, [ g7 Cooling Towers (A6tHf The coo'ing towers are constructed offcombustible PVC material.
This does not meet the guidelines of BTP CMEB 9.5-1, Section C.7.
The sole source of fire suppression water is provided from the cooling tower We [ require that automatic cuppression system be provided basins.
in accordance with the guidelines of NFPA 214-1977 and Section C.7.g of BTP CMEB 9.5-1.
C
,[hjOtherPlantAreas e applicant's fire hazards analysis addressed other plant areas not specifically discussed in this report The staff finds that the fire protection for these areas is in acco)rdance with the guidelines of BTP CMEB 9.5-1 and therefore, acceptable.
ORAR
. f, f /, [
-9&tt Summary of Deviations from CMEB 9.5-1 The technical requirements of Appendix R to 10 CFR and Appendix A to BTP ASB 9.5-1 have been included in BTP CMEB 9.5-1.
-Listed below are the deviations from the guidelines of BTP CMEB 9.5-1 that have been
_ u____
m__
u__-
- approvedJ aad +hav =re = f" 1 1 "-+ -
1.
Main & Plant Service Transformers, Section C.S.a 2.
Lighting & Communications Cables, Section C.S.e 3.
Ventilation, Section C.S.f 4.
Portable Radios, Section C.S.g f { /, g Conclusion The following are the open fire protection itemsre M
N5 d[a
/
r>y ;
1.
Fre Protection'. Program x~r>rm BTP CMEB-92 5-1-Se~ction: C^rl. a c9 : PV "
2.
Fire Hazards Analysis BTP CMEB 9.5-1 Section C.1.b 3.
Administrative Controls BTP CMEB 9.5-1 Section C.2-4.
Fire Brigade Size BTP CMEB 9.5-1 Section C.3 5.
3-hour Fire Barriers BTP CMEB 9.5-1 Section C.5.a 6.
Penetration Seals BTP CMEB 9.5-1 Section C.S.a 7.
Fire Doors BTP CMEB 9.5-1 Section C.5.2 8.
Metal Roof Oeck Construction BTP CMEB 9.5-1 Section C.5.2 9.
Floor Drains BTP CMEB 9.5-1 Section C.S.2 10.
Stairwell Enclosures BTP CMEB 9.5-1 Section C.S.a 11.
Safe Shutdown BTP CMEB 9.5-1 Section C.5.b 12.
Alternate Shutdown BTP CMEB 9.5-1 Section C.S.c 13.
Control of Combustible Gases BTP CMEB 9.5-1 Section C.5.d 14.
Line Type Heat Detectors &
BTP CMEB 9.5-1 Section C.S.e Suppression BRAN I
?
,9 j
~ 15.
Power Supplies for BTP CMEB 9.5-1 Section C.S.f Ventilation 16.
Energency Lighting BTP CMEB 9.5-1 Section C.S.g 17.
Fire Detection BTP CMEB 9.5-1 Section C.6.a 18.
Jockey Pump BTP CMEB 9.5-1 Section C.6.b 19.
Valve Supervision BTP CMEB 9.5-1 Section C.6.c 20.
Branch Connections for BTP CMEB 9.5-1 Section C.6.c Standpipes 21.
Hose Station Coverage BTP CMEB 9.5-1 Section C.6.c 22.
3" dia standpipes BTP CMEB 9.5-1 Section C.6.c 23.
Seismic Suoport of Stand-8TP CHEB 9.5-1 Section C.6.c pipes
- 24. PGCC Halon System BTP CMEB 9.5-1 Section C.6.d 25.
Separation of Safety-related BTP CMEB 9.5-1 Section C.7.a Components in Containment 26.
Control Room Complex BTP CMEB 9.5-1 Section C.7.b 27.
Suppressicn-in=ControlaRoom w BTPaCMEBn9:5-1 Section:@ 7eb d T-Ceiling 28.
Detection in Control Room BTP CMEB 9.5-1 Section C.7.b Cabinets 29.
Cable Spreading Room, 3-hour BTP CMEB 9.5-1 Section C.7.c Barrier 30.
Switchgear Rooms - Drains BTP CMEB 9.5-1 Section C.7.e and Exposed Structural Steel 31.
Separation of PGCC Panels BTP CMEB 9.5-1 Section C.7.f 32.
Battery Rooms Exposed -
BTP CMEB 9.5-1 Section C.7.g Structural Steel 33.
Diesel Generator Separation BTP CMEB 9.5-1 Section C.7.1 34.
Cooling Towers Suppression BTP CMEB 9.5-1 Section C.7.g